US Shipping Surcharges: Why Cargo Receipt Dates Matter

CMA CGM’s Black Sea War Risk Surcharge starts on 9 November 2026 for most of the world and on 1 December for the US and US territories. Maersk’s new dry port charges at Virochannagar, India, took effect on 1 November for non-regulated countries and start on 29 November for regulated countries.

A customer quoted off the first date can see a charge that was not yet in effect on their box. Treating the second date as a grace period for every lane has the opposite effect, and cargo already exposed goes unbudgeted. Which date applies comes down to the covered trade, equipment and contract terms. For US tariff cargo, the relevant rates and charges are those in effect when the carrier or its agent receives the cargo.

Which surcharge date applies to my shipment?

Your shipment	Date to plan on	What to confirm
US trade, published tariff	The US effective date in the applicable tariff	When the carrier or its agent received the cargo, including an originating carrier under through transportation
US trade, service contract	Check the contract and any relevant tariff provisions it incorporates	Surcharge authority, notice terms, caps and the applicable pricing event
Australia, New Zealand or a Latin American country covered by CMA CGM’s later-date group	1 December 2026 for this Black Sea WRS announcement	Country coverage and local filing treatment
Notice says only “regulated countries”	Keep both announced dates in view until the carrier confirms your country’s group	The classification and effective date for the particular charge
Other shipments within the notice’s covered scope	The earlier date, if no separate country date applies	Origin, destination, equipment and the event that determines applicability

A starting point for reading a two-date notice. The applicable tariff and contract terms govern billing.

Why do surcharges start later in the US?

US federal rules bar a new or increased rate or charge in a published tariff from taking effect earlier than 30 calendar days after publication. The rule is 46 CFR §520.8(a)(1). A carrier can start other trades sooner where no comparable rule applies, so one surcharge ends up with two dates.

We looked at how this rule works on rate increases in Do Shipping GRIs Stack? On surcharges, the visible result is the date split in these notices:

Carrier and charge	Amount	First date	Later date	Later date covers
CMA CGM War Risk Surcharge, Black Sea	US$35 per TEU, all cargo	9 Nov 2026	1 Dec 2026	USA and US territories, Australia, New Zealand, Latin American countries subject to regulatory filings
Maersk Dry Port Surcharges, Virochannagar	Export DPS: INR 6,770 per 20ft dry; INR 8,190 per 40ft dry or high-cube dry. Import DPI: INR 6,300 and INR 11,300 respectively	1 Nov 2026	29 Nov 2026	“Regulated countries”, not enumerated in the announcement
Maersk Congestion Fee Destination, Far East Asia, Indian Subcontinent and Middle East to Durban	US$450 per 20ft, US$900 per 40ft; China origins US$400 and US$800	1 Nov 2026, non-regulated countries and Vietnam	8 Nov 2026	Korea and Taiwan
ONE Emergency Fuel Surcharge, long-haul head haul	US$150 per TEU dry, US$190 per TEU reefer	1 Nov 2026	Same announced date	FMC-regulated trades and Canada also listed for 1 November, subject to required approvals and notice periods

Selected carrier announcements checked on 4 November 2026. Amounts and dates must be matched to the covered scope, governing tariff and contract.

Maersk’s Virochannagar export rows cover carrier-owned equipment; its import rows cover both carrier-owned and shipper-owned equipment. The announcement lists 20ft dry, 40ft dry and 40ft high-cube dry containers.

A shared effective date can still allow for the notice period. ONE’s 1 October advisory announced the November EFS levels 31 days before their stated start. Its earlier September increase also used the same announced date for FMC and non-FMC trades. Both advisories remained subject to required regulatory approvals and notice periods.

Count from tariff publication. CMA CGM’s global advisory is dated 30 October, 32 days before its stated US date. Maersk’s public Virochannagar advisory is dated 2 November, 27 days before its regulated-country date. Neither webpage date establishes when the applicable tariff was published. Ask for the tariff publication and effective dates if a charge appears to start too soon.

What does “regulated countries” mean in a carrier notice?

Maersk’s Virochannagar announcement does not list the countries in its regulated group. CMA CGM names its later-date group, although it does not enumerate the Latin American countries subject to regulatory filings. Confirm the classification for the particular notice before assigning a date to your shipment.

Date splits also reach beyond the US. Maersk’s 8 October Durban notice gives Vietnam the same date as non-regulated countries and gives Korea and Taiwan a date one week later. Maersk’s 16 July advisory also gave a peak season surcharge from listed Far East origins to Jawaharlal Nehru, Mundra, Pipavav and Pakistan a 22 July start, with South Korea from 3 August. That announcement excluded SPOT bookings.

The legal explanation here concerns the US rule. A shared date on a carrier notice does not establish that the countries share a statute or a notice period.

Which date decides my container?

For US tariff cargo, 46 CFR §520.7(c) requires the applicable rates, charges and rules to be those in effect when the common carrier or its agent receives the cargo. That includes receipt by an originating carrier under through transportation. The vessel’s loading date and the invoice date do not replace this test. The FMC restated the point in its March 2026 statement on Hormuz surcharges.

Illustrative US export to Constanța	Received by carrier	Loaded	New Black Sea WRS at receipt
Shipment A, one 20ft container	28 Nov 2026	3 Dec 2026	Not yet in effect
Shipment B, one 20ft container	2 Dec 2026	6 Dec 2026	In effect, US$35

Hypothetical, separately rated tariff shipments. Assumes the governing tariff makes this WRS effective on 1 December and that the stated dates are the legally relevant cargo receipt dates.

Pull the receipt records for the booked transport arrangement, including any inland handover under a through move. Port gate-in may occur after the relevant receipt. Outside US tariff scope, carrier notices can use loading, B/L, gate-in or price calculation dates.

CMA CGM’s global Black Sea announcement does not specify a shipment event, but its UAE advisory refers to B/Ls from 9 November, subject to regulatory filings. It names Constanța, Poti, Varna and Burgas, plus other regional ports the carrier serves. Its Pakistan advisory also includes feeder movements and inland markets served through Constanța and Poti. Confirm the applicable local advisory and tariff for the route; the UAE wording does not establish the trigger for US tariff cargo.

The financial exposure is larger on charges such as Maersk’s peak season surcharge from listed Indian Subcontinent and Middle East origins to the US and Canadian West Coast. Its 22 October advisory revised that charge to US$3,400 per listed dry or reefer container type from 23 October. It excludes SPOT bookings and defines the FMC non-SPOT pricing event as last-container gate-in. That separate pricing rule should be checked against the governing tariff and contract before applying a container-by-container calculation.

A multi-container booking can have gate-ins on both sides of an effective-date boundary. Keep each container’s timestamps, then confirm whether the applicable rule rates the containers separately or uses a shipment-level event. If your team reconciles shipment milestones with surcharge notices, see how ops teams follow container milestones across carriers in one view.

Can a carrier skip the 30-day wait?

Outside the specific regulatory exceptions, a carrier needs special permission from the FMC to introduce a tariff increase on shorter notice. Under 46 CFR §520.14, the carrier must show good cause and apply by letter. Plan around the ordinary notice requirement unless an approval authorizes an earlier date for the particular charge.

23 March 2026: the FMC denied four requests for war risk or conflict surcharges on short notice from CMA CGM, Hapag-Lloyd, Maersk and ZIM. Explaining her vote, Chair Laura DiBella said an assertion of higher costs without supporting data is “insufficient in demonstrating good cause.”
3 April 2026: the FMC denied a further Maersk special-permission application. Husch Blackwell’s analysis published on 16 April counted requests from five vessel-operating carriers and two NVOCCs, including repeat applications, with every application denied except one that was withdrawn.
The earlier pattern: Husch Blackwell says about a dozen carriers received approval in late 2023 and early 2024. A majority vote of the commissioners has been required since 2025.

You can see earlier phased implementation in our April rate table. ONE’s Emergency Fuel Surcharge had announced starts of 24 March for non-FMC trades and 9 April for FMC trades and Canada. OOCL’s Emergency Bunker Surcharge had announced starts of 23 March outside FMC scope and 13 April within it. For a newer surcharge, check whether the FMC has granted special permission for that charge.

Narrower exceptions include rates for US Department of Defense cargo. A collection-agent exception under 46 CFR §520.8(b)(4) covers certain changes outside the carrier’s control when the carrier merely collects the charge, the entity making the change does so without notifying the carrier, and the carrier does not mark it up above cost.

Do surcharge cuts have to wait 30 days?

Generally, no. Under 46 CFR §520.8(a)(4), a tariff change that decreases a shipper’s cost may take effect on publication. A carrier can still set a later date, so read the new notice and applicable tariff. Government-controlled carriers are subject to separate rules under 46 CFR §565.7, which can require a notice period for reductions as well.

Does the 30-day rule apply to service contract cargo?

It depends on the contract. The FMC says that when a service contract incorporates all or part of a carrier’s published tariff, the associated rates, charges or rules apply based on their effective date at cargo receipt. Read the relevant incorporation language alongside any express surcharge provisions. Husch Blackwell cautions that shippers should not assume new surcharges are automatically enforceable under existing contracts, and points to surcharge authority, notice terms and caps as the clauses to check.

If an NVOCC is your contracting carrier, check its tariff or applicable negotiated terms. If a forwarder acts as your agent, identify the carrier agreement governing the shipment. Ask which charge and pricing event will be used for billing.

Frequently asked questions

Is 1 December the start date for every US shipment under CMA CGM’s Black Sea surcharge? It is the notice’s date for the US and US territories. On tariff cargo, the test is whether the charge was in effect when the carrier or its agent received the cargo. Contract cargo depends on the contract terms.
Does the 30-day clock start when a notice appears in the news? No. It runs from publication in the tariff, and a news report does not show that date.
Do Australia, New Zealand and Latin America follow the US 30-day rule? A shared effective date does not establish a shared legal notice period. CMA CGM names Australia, New Zealand and Latin American countries subject to regulatory filings for 1 December. Confirm the applicable country and filing treatment with the carrier.

What to check before the November and December changeovers

List affected Black Sea and Virochannagar bookings, then identify the applicable country group and equipment scope.
Identify the governing tariff or service contract, and read any tariff incorporation and surcharge clauses.
Ask Maersk which countries count as regulated on any notice that touches your lanes.
For Black Sea moves, confirm coverage of the actual port, feeder leg and any inland destination, along with the applicable receipt or pricing event.
Keep receipt and gate-in records with the notice, including any inland handover and last-container timestamp relevant to the governing rule.
Re-quote customers with the date for their lane, in place of the headline date.

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